I am an individual investor. I do not consider inverse and leveraged ETPs to be complex. Inverse ETPs are an intuitive and straightforward way for the average investor to hedge against long positions in their 401K using a self-directed trading account. My colleagues and I have learned that it can be counterproductive to move funds in our 401Ks into cash and back into long term investments, given the limited number of exchanges allowed and end of day pricing. Instead, we at times will hedge our long term investments using inverse ETPs in other accounts. In this way we can use limit orders and set appropriate stops. We do not want to see restrictions placed on this as it will encourage the bad practice of trading in our 401Ks, which doesn't allow limit orders and stops.
With respect to leveraged ETPs, I personally avoid them. I use them only when a -1X ETP is not available for the particular asset class or the volume is too low. However, I appreciate that many investors have small trading accounts in relation to their 401Ks and seek out leveraged ETPs in order to sufficiently hedge their long term positions.
Other individual traders will use inverse and leveraged ETPs to simply play both sides of markets. These ETPs are intuitive and straightforward for them too. The alternative is using short selling and put options, which is arguably riskier and more complex.
I hope you will focus efforts on new restrictions to the truly complex instruments and allow current obligation practices to continue for inverse and leveraged ETPs.
Mike Ott Comment On Regulatory Notice 22-08
I am an individual investor. I do not consider inverse and leveraged ETPs to be complex. Inverse ETPs are an intuitive and straightforward way for the average investor to hedge against long positions in their 401K using a self-directed trading account. My colleagues and I have learned that it can be counterproductive to move funds in our 401Ks into cash and back into long term investments, given the limited number of exchanges allowed and end of day pricing. Instead, we at times will hedge our long term investments using inverse ETPs in other accounts. In this way we can use limit orders and set appropriate stops. We do not want to see restrictions placed on this as it will encourage the bad practice of trading in our 401Ks, which doesn't allow limit orders and stops.
With respect to leveraged ETPs, I personally avoid them. I use them only when a -1X ETP is not available for the particular asset class or the volume is too low. However, I appreciate that many investors have small trading accounts in relation to their 401Ks and seek out leveraged ETPs in order to sufficiently hedge their long term positions.
Other individual traders will use inverse and leveraged ETPs to simply play both sides of markets. These ETPs are intuitive and straightforward for them too. The alternative is using short selling and put options, which is arguably riskier and more complex.
I hope you will focus efforts on new restrictions to the truly complex instruments and allow current obligation practices to continue for inverse and leveraged ETPs.